"John has been a pleasure to work with on the board and in the Executive Committee. The more I’ve gotten to know John, the more I appreciate his skills." --Brett LaDove, Past President, Institute of Management Consultants

"I find it fantastic how I can just throw you into almost anything and you use your knowledge of process and technical organizations to do the job well." --Jennifer Selby Long, Owner, Selby Group

Compliance Systems Development

Fortify your comliance program with direction, policies, processes, and proper organiztion and storage of evidence.

Build government business with confidence by ensuring effective contract (e.g. General Services Administration ) compliance.

Ensure financial controls (e.g. Sarbanes-Oxley) are effective by building an audit and self-assessment program.

Align governance, risk, and compliance into a holistic system that protects the interests of all stakeholders, and insulates your organization against the effects of the unknown.

Thoughts on Compliance

Contract Compliance 101

What would happen if one of your biggest client contracts were audited tomorrow? Would you be okay, or would there be "findings"?

There is no sense in leaving your biggest client contracts exposed to an unfavorable audit. With a relatively simple framework, and a little effort, you can fortify your most important contracts (e.g. your General Services Administration contract). Six Sigma defines a well-known and respected five-step process for improving processes and building quality products.

No, I'm not suggesting that you break out the black belts, stat-heads, and large wallet, but the basic framework can be transposed to fortify the fulfillment of any contract obligations. Let's go through the DMAIC (the basic Six Sigma process improvement framework) process, and see how it can apply to contract compliance.

Step 1 - DEFINE

As with all initiatives, you should clearly define what you're trying to accomplish, and establish a charter. Even if it's a small effort, I would call it a "project", so the first step would be to establish a Project Charter. Voice of Auditor (VOA) data should also be collected. This can be from external auditors, internal auditors, and anybody else that would have feedback on what needs to be done to improve contract conformance.

Step 2 - MEASURE

An Operational Contract is a contract that puts your legal contract in very unambiguous terms, with strict definitions around each term. The Data Collection Plan spells out the procedure for how you will collect your data for contract compliance. To baseline conformance, simply run through your Data Collection Plan and record the data.

There is no sense in leaving your biggest client contracts exposed to an unfavorable audit. With a relatively simple framework, and a little effort, you can fortify your most important contracts (e.g. your General Services Administration contract).

Step 3 - ANALYZE

After you have baselined your contract conformance, discuss what areas need to be improved, and brainstorm on possible root causes for why certain contract points are either out of compliance, or close to it.

Once your improvements have been made, you need to run tests to ensure the fix will "hold." An Auditor's Test Plan is an extension of your Data Collection Plan. It should be created from an auditor's point of view, and integrate seamlessly with your Data Collection Plan. The results from executing your test plan should be recorded in your Control Plan. Your Control Plan spells out what should be expected from your testing efforts, and highlights when something is "out of control," or not acting the way it should.

The 5-Step Six Sigma DMAIC (Define, Measure, Analyze, Improve, Control ) process is an effective way to fortify the conformance of your most important contracts. Contact us today if you would like to chat more about your organization’s compliance.

Let's Be Social

Government Compliance, Hewlett Packard

At Hewlett Packard, John worked with the government compliance program office to build a data system and operational processes for compliance with their General Services Administration (GSA) program. John systematically analyzed large volumes of data to ensure conditions for their price reduction clause (PRC) were properly managed and reported. John also advised and aided compliance program officers with analysis on commercial sales practices (CSP) in preparation for contract negotiations.

Michael F. Mason, Hogan & Hartson

I want to thank you very much for your support in our GSA litigation effort. We appreciate your ability to quickly model the client’s landscape, and provide insightful data investigation, discovery, and statistical analysis. Because of your incredible turnaround we were able to build a solid, data-based defense very quickly....

Six Sigma Black Belt

Trained at Motorola, USA, where Six Sigma was originally developed, under the best Master Black Belts in the world. Six Sigma uses a set of quality management methods, including statistical methods, to improve the quality of process outputs. A Black Belt is the highest ranking practitioner on any project, responsible for leading the team and performing more advanced statistical analysis.